CLA-2-85:OT:RR:NC:N2:208
Ernesto Navidad
Creation Technologies Washington LLC
6300 Merrill Creek Pkwy
Everett, WA 98203-1577
RE: The tariff classification of cameras from China
Dear Mr. Navidad:
In your letter dated October 29, 2025, you requested a tariff classification ruling.
The merchandise under consideration is the CameraCubeChip® modules, model number OVM6946-RAJH,
which are compact camera modules designed for single-use applications in endoscopes, such as
bronchoscopes. Moreover, the CameraCubeChip® modules are surface-mount miniature cameras that are
installed, after importation, at the distal tip of disposable bronchoscopes. These cameras capture video
images and transmit them outside the camera for remote viewing and recording. The subject camera modules
do not have any internal recording capability.
The applicable subheading for these CameraCubeChip® modules will be 8525.89.3000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Transmission apparatus for radio-broadcasting
or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus;
television cameras, digital cameras and video camera recorders: Television cameras, digital cameras and
video camera recorders: Television cameras: Other.” The rate of duty will be Free.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 10 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 8525.89.3000, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. At the time of entry,
you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition
to subheading 8525.89.3000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8525.89.3000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e.,
9903.88.03, in addition to subheading 8525.89.3000, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided
for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying
duty rates are provided at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents
filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact
National Import Specialist Lisa Cariello at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division